When a company is sold, it is often partly for consideration which is deferred in one way or another. Sometimes this will take the form of a debt, such as loan notes. Effectively, the vendor is lending the purchaser the balance of the consideration. If certain conditions (set out in s.117 TGCA 1992) are met, the loan notes will be "qualifying corporate bonds". There are specific considerations that need to be made in such cases.
Where shares are exchanged for QCBs s.116(10) TCGA 1992 applies automatically such that, any…
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